Wicor, Inc. v. United States

DECISION AND ORDER

GOODSTEIN, United States Magistrate Judge.

Wicor, Inc., and its subsidiaries bring this action against the United States to receive a federal income tax refund under 26 U.S.C. §§ 41 and 1341. The § 41 and § 1341 issues were bifurcated and, on September 30, 1999, this court granted the defendant’s motion for partial summary judgment, wherein the court denied the plaintiffs request for an income tax credit under § 1341.

On April 19, 1999, a trial to the court was conducted on the plaintiffs claim that it is entitled to a research credit under § 41. Following the trial, the…